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The far-reaching significance of effectively connected income by Shannon R. Jemiolo, Ian Redpath and Eric M. Redpath

By: Jemiolo, Shannon R.
Contributor(s): Redpath, Ian | Redpath, Eric M.
Material type: ArticleArticleSubject(s): IMPUESTOS | EXTRANJEROS | NO RESIDENTES In: Tax Notes International v. 117, n. 5, February 3 2025, p. 717-733Summary: In this article, the authors argue that understanding what constitutes effectively connected income versus fixed or determinable annual or periodic income is paramount in tax planning for nonresident aliens and foreign corporations, and that tax practitioners must structure U.S.-source income streams to provide the most advantageous tax treatment.
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OP 138-Bis/2025/117/5-4 (Browse shelf) Available OP 138-Bis/2025/117/5-4

In this article, the authors argue that understanding what constitutes effectively connected income versus fixed or determinable annual or periodic income is paramount in tax planning for nonresident aliens and foreign corporations, and that tax practitioners must structure U.S.-source income streams to provide the most advantageous tax treatment.

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